Apex Market Report · Architects BSA 2022 · Q3 2026

Architects BSA 2022 Impact Report — Q3 2026

Compiled by Matthew Bartlett, Director, Apex Insurance Brokers Limited · Published 15 July 2026 · Quarterly series

Executive summary

The Building Safety Act 2022 has fundamentally repriced architects PI. Section 135's 30-year retrospective and 15-year prospective limitation on higher-risk buildings has moved the tail exposure from six years to three decades on residential work above 18m or 7 storeys.

Insurer appetite has bifurcated. Practices with clean claims history and no BSA-touching residential exposure see stable renewals. Practices with material BSA exposure face rate loading of 15-40% and, in some cases, insurer exit.

Run-off cover for retiring architects has become materially more expensive. Standard six-year run-off (~250-350% of final annual premium) is no longer adequate for practices with BSA-touching residential work in their file. Extended run-off (12+ years) at 400-800% of final annual is now the required norm.

1. What BSA 2022 s.135 actually does

The Building Safety Act 2022 came into force in stages from April 2023. Section 135 extends the limitation period for defective premises claims under section 1 of the Defective Premises Act 1972:

Retrospective: for work completed before 28 June 2022, the limitation period is now 30 years from the date the cause of action accrued.
Prospective: for work completed after 28 June 2022 on higher-risk buildings, the limitation period is 15 years.

‘Higher-risk buildings' (HRB) are defined in the BSA and its subordinate regulations as buildings with at least 18 metres in height OR at least 7 storeys AND containing at least 2 residential units. This captures a substantial proportion of urban residential-block work.

The practical implication for architects: professional negligence claims against work on higher-risk buildings can now be brought decades after the work was performed. A practice designing a residential block in 2010 remains exposed until 2040 under the retrospective 30-year rule.

2. Principal Designer role and BSA

The BSA introduces a new statutory duty-holder framework for higher-risk buildings under the RBCA (Relevant Building Contract Act) regime. The Principal Designer role has been reshaped, and architects acting as Principal Designer on HRB projects face specific new obligations:

Design safety competence: the Principal Designer must be competent in fire safety and structural safety of the specific building type.
Design safety file: mandatory maintenance of a comprehensive design safety file passed forward to the building owner.
Gateway 2 and 3 sign-off: the Principal Designer participates in the Building Safety Regulator's Gateway process, with specific declaration duties.
Coordination with Principal Contractor: statutory duty to coordinate design and construction phase safety.

The PI implications are material: any breach of these statutory duties creates civil liability exposure. Standard architects PI wordings extended pre-BSA may need specific endorsements to confirm coverage of the new statutory role.

3. Insurer appetite for BSA-touching work

Insurer appetite for architects PI in Q3 2026 shows clear bifurcation by BSA exposure:

Zero BSA exposure

Commercial, non-residential, small residential (below HRB threshold). Rate: 0.5-2% of fee income. Broad insurer competition.

Modest BSA exposure

Some HRB work in the file. Rate: 1.5-3.5%. Insurer scrutiny on file depth and Principal Designer arrangements.

Material BSA exposure

HRB residential is significant proportion of file. Rate: 2-4%+. Wholesale market attention. Detailed BSA file review at underwriting.

Historic residential-block file

Pre-2022 residential work now under 30-year retrospective. Some insurers restrict; others price aggressively. Practice-specific outcomes vary.

4. Extended run-off cost

Standard six-year run-off cover is priced at 250-350% of the final annual premium. This was sufficient for pre-BSA architects PI where the practical tail was six years from cessation. Post-BSA, standard six-year run-off leaves 24 years of potential tail uncovered on HRB work.

Q3 2026 run-off market pricing for architects retiring with BSA exposure:

Six years: 250-350% of final annual. Adequate only for practices with zero BSA-touching residential in the file.
12 years: 450-600%. Reasonable for practices with modest BSA exposure completed pre-2022.
15 years: 550-750%. Matches prospective BSA limitation for HRB work completed post-2022.
30 years: 700-1,000%+. Bespoke pricing. Required for practices retiring with material historic HRB work under retrospective 30-year limitation.

The market for genuinely long-tail architects run-off (15-30 years) is narrow. Specialist wholesale broker relationships matter here. Retiring architects with BSA exposure should be engaging their broker at least 12 months before intended cessation.

5. ARB Standard 8 adequacy debate

ARB Standard 8 requires architects to maintain ‘adequate' PI cover. Pre-BSA, adequacy was widely interpreted as market-standard cover with six-year run-off. Post-BSA, the adequacy standard is more complex:

Cover limit: a claim from BSA-touching work 25 years post-completion could reach quantums that make historic £250k or £500k cover materially inadequate.
Run-off length: six years leaves clear exposure gap on HRB work.
Wording extensions: Principal Designer statutory duties should be specifically covered.

ARB has not published formal guidance updating ‘adequate' in the BSA context. In the absence of formal guidance, the market convention is that practices with material BSA exposure hold:

Materially higher per-claim limits than the pre-2022 norm (£2m-£5m minimum, higher for BSA-heavy practices)
Explicit Principal Designer coverage extension
Extended run-off (12-30 years depending on file)

6. Recommendations for architects at renewal

Document your BSA exposure explicitly. Insurers now underwrite on HRB volume. A clear disclosure of BSA-touching residential work in the file, with volume by year and Gateway progression, materially improves underwriting outcomes.
Review cover-limit adequacy. Pre-2022 cover of £250k or £500k may no longer meet ARB Standard 8 adequacy for practices with BSA exposure. Consider stepping up.
Confirm Principal Designer wording extension. Standard pre-BSA wordings may not explicitly cover the new statutory duties.
Plan run-off cover 12+ months ahead of cessation. Extended run-off (12-30 years) market is narrow and lead-times matter.
Engage a specialist broker for BSA-touching placements. Standard-market brokers with limited BSA experience may not identify appropriate wholesale market appetite.

7. Apex commentary

Apex Insurance Brokers is a directly-authorised specialist broker with 17 years placing architects PI. We place across specialist insurers direct plus wholesale Lloyd's markets. BSA 2022 s.135 exposure is a specialism.

Three observations from our Q3 2026 architects renewal book:

Insurer capacity for BSA-heavy practices remains functional but narrower. Practices with material HRB work face fewer active insurers than in the pre-2022 general market. Wholesale Lloyd's access matters more than at any point in recent memory.
Documentation discipline is the largest single variable in outcomes. Practices presenting complete BSA-file documentation (project list with HRB status, Principal Designer arrangements, Gateway progression, safety-file completeness) see materially better rates than practices presenting bare Q&A questionnaires.
Retirement planning has become a strategic conversation. Architects with material historic HRB work in the file who intend to retire in the next 5-10 years should be planning run-off cover now. Costs are only heading in one direction.

Data notes and methodology

Rate movement bands are indicative of the Apex architects renewal book Q2 → Q3 2026 combined with publicly-available market commentary.
Run-off cost bands are indicative and depend on final annual premium, claims history, and BSA-file profile.
BSA 2022 s.135 provisions are as enacted 28 April 2022 and brought into force from June 2022. RBCA regime and Principal Designer duties as under the BSA and subordinate regulations.
This report is a market commentary for information purposes. It is not regulated advice on any specific placement. Individual architects should consult their broker for firm-specific renewal or run-off strategy.